Tax
Why Bulgaria
Bulgaria is one of Europe’s most attractive jurisdictions for tax-efficient structuring for both individuals and businesses. Its flat 10% personal and corporate income tax rates, 5% dividend tax, extensive double tax treaty network covering more than 70 countries, and EU membership make it a compelling option for those seeking to optimise their tax position within a transparent and EU-compliant framework.
For business owners, entrepreneurs, and private clients, Bulgarian tax residence offers a cost-effective alternative to more traditional European jurisdictions. The absence of progressive taxation can significantly reduce the effective tax burden, while certain capital gains from securities traded on regulated EU and EEA markets may benefit from favourable treatment.
The Bulgarian Tax Landscape
Bulgaria offers a structured and predictable regulatory environment, with clear tax residence criteria, a developed withholding tax regime, and a long-standing international treaty network. Sofia and the wider Bulgarian legal market provide access to experienced tax advisers at competitive cost.
Incorporating a Bulgarian company may be particularly attractive for start-ups and businesses restructuring within the EU. Bulgarian law provides both standard commercial company forms and a type of company that can be incorporated without opening a bank account or contributing share capital.
Regulatory Framework
The Bulgarian tax system is governed by a comprehensive framework of domestic legislation, including rules on personal income tax, corporate tax, VAT, dividend and withholding taxation, local taxes, inheritance and gift taxes, and tax procedure.
As an EU Member State since 2007, Bulgaria applies harmonised EU tax rules. Its VAT, corporate, dividend, anti-avoidance, tax reporting, and administrative cooperation regimes are aligned with relevant EU directives, including DAC6 and ATAD. Bulgaria is also a party to the Multilateral Instrument, which updates much of its double tax treaty network in line with BEPS standards.
Cross-border tax matters are further governed by Bulgaria’s treaty network, which allocates taxing rights, reduces withholding taxes, and provides mechanisms for avoiding double taxation.
Our role is to guide clients through this framework, explain how Bulgarian law, EU rules, and treaty provisions apply to their circumstances, and develop tax positions and structures that are effective, robust, and fully compliant.
Our Approach
NBLO team provides comprehensive legal and tax support to individuals and legal entities in the application of national and international tax law. Our approach combines in-depth analysis of the applicable legislation with a practical understanding of the cross-border aspects of tax residence, corporate taxation, and double tax treaties.
Our Services
Tax Residency Advisory
Establishing, documenting and defending Bulgarian tax residency under PITA — including the 183-day rule, centre of vital interests analysis, treaty tie-breakers and Tax Residency Certificates issued by the NRA.
Personal Income Tax & Compliance
Application of the 10% flat rate to worldwide income for residents, annual filings, foreign tax credits, and tax-efficient treatment of dividends, capital gains and employment income.
VAT Advisory
Mandatory and voluntary VAT registration, intra-Community acquisitions, reverse-charge mechanics, monthly returns, and preparation for the Standard Audit File for Tax (SAF-T) regime from 2026.
Cross-Border Tax Planning & Treaties
Multi-jurisdictional structuring, application of Bulgaria’s 70+ double taxation treaties, and entry and exit planning for clients changing residence.
Dividend & Withholding Tax
The 5% dividend rate, Parent-Subsidiary Directive exemptions, treaty-based reductions on dividends, interest, royalties and service fees, and structuring of cross-border distributions.
Inheritance, Gifts & Wealth Transfer
Bulgarian tax treatment of inheritances and lifetime gifts, cross-border estate planning, and integration with wills, trusts and family holding structures.
Real Estate & High-Value Assets
Transfer tax and VAT on property transactions, ongoing local taxes, and tax planning for yachts, aircraft and other high-value movable assets entering the EU customs and VAT territory.
Tax Disputes & Representation
Voluntary disclosures, administrative appeals, litigation before the administrative courts and Supreme Administrative Court, and Mutual Agreement Procedures under treaty law.
EU & International Compliance
DAC6, CRS, Pillar Two and beneficial ownership reporting, scaled and calibrated to the structure of the client’s affairs and the jurisdictions involved.